Loan & Distribution Specialist AimPoint Pension
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AimPoint Pension
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Compass
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Bates & Company, Inc.
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Regional Vice President of Sales The Retirement Plan Company
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Who Does the DOL's Conflict of Interest Rule Apply To?
Morningstar; free registration may be required Dec. 2, 2016 "[A] 3(21) administrative fiduciary is irrelevant because it has nothing to do with investing.... We can also ignore ... a 3(21) discretionary decision-maker such as an ERISA section 3(38) investment manager -- because, in making such decisions, the benefits of the Rule are not available to fiduciaries that receive variable compensation in exchange for rendering discretionary investment advice ... [It's] only ... a 3(21) non-discretionary advice-giver which the Rule pertains to: [1] a fiduciary [2] that renders (non-discretionary) investment advice [3] for compensation. All three of these elements must be present in order for the Rule to apply to an advisor communicating with a plan participant or an IRA owner." |
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